Legal Opinion
Applestein v. Director, Division of Taxation
New Jersey Tax Court
Decided December 27, 1982PublishedCited by 4 opinions
1Opinion of the Court
CONLEY, J.T.C.
This case involves plaintiff’s challenge to an assessment of $2,336.81 plus interest under the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1 et seq. In his complaint plaintiff recites that in 1977 he engaged in numerous “arbitrage operations” involving the purchase of many thousands of shares of stock and that he incurred $93,362 in interest charges associated with the transactions. Plaintiff also incurred New York City stock transfer taxes of $110. It is plaintiff’s position that his trading operations “should be treated as a business” so that he could deduct interest and…
2Cases cited10 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Polachek v. CommissionerUnited States Tax Court · 1954
- Ralph E. Purvis and Patricia Lee Purvis, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Wiesler v. CommissionerUnited States Tax Court · 1946
5 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Smith v. Director, Division of TaxationSupreme Court of New Jersey · 1987
- Marrinan v. Division of Taxation, DirectorNew Jersey Tax Court · 1989
- John F. v. Director, Division of TaxationNew Jersey Tax Court · 1991
- Applestein v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 1984